A complete Digital Complaints Management System (DCMS) for professional football Clubs.

One of the major problems facing complaints management, is the disparate nature of football organisations. Departments may be in alternative locations, even in different towns. Further, there may not be much interaction between Departments, with email being the only common form of communication.

This is often the case, even with all Departments in the same location. The DCMS provides a centralised resource, that receives, sends and stores all relevant emails, documents, investigations etc., and makes them available to all parties.

Where a complaint is time sensitive, for example in a Subject Access Request (SAR), or a Data Breach, the system will send warning messages to designated staff, at pre-determined intervals, to ensure that deadlines are complied with.

For example, in relation to a SAR, at 7, 14, 21, 28 and 30 days. This makes it almost impossible not to comply with the legislative deadlines, enabling the avoidance of crippling fines for non-compliance. The DCMS automatically notifies at least two staff of the arrival of a complaint, to ensure that nothing is missed.

Complaints are submitted through a dedicated entry page, linked to from a Club’s existing website and privacy documents, with email verification before a case is created.

This ensures that every complaint enters the system cleanly and securely, removing the risk of items being lost in personal inboxes. Correspondents are guided through an entry form, which gives them the opportunity to choose the type of complaint, supply any relevant account number, attach documents and provide relevant information.

The DUA has also provided various new rights to the ICO. These include the power to summon staff as witnesses, to demand the presentation of documents and to mandate an organisation to pay for an external expert to investigate a complaint.

Anyone involved in this field of work will know how difficult it is to comply with these requirements, when all documents, evidence etc. is spread across different email accounts, social media etc. The DCMS provides an evidence log, that can simply be printed, that includes a timeline of events.

Drawing upon vast experience of the professional football environment, a suitable permission-based user management system has been developed. The system requires a designated IT Manager, and a designated DPO. Both roles are notified of the initial receipt of a complaint.

These positions have varying administrative powers, such as the creation of Departments, users etc. Dependent upon the size of a Club, numerous Departments and users can be created. When a complaint is received, it can be assigned to an appropriate Department/user to investigate.

As well as managing complaints, the DCMS provides a wide range of software tools to help a DPO, or the person that has the DPO responsibility, to manage the complete compliance process.

These include specialist areas for the various documents and processes that must be completed, including ICO Case Management, Audit Records, Certification, DPIAs and DRAs. There is also a document vault. Certain of the sections, that are date sensitive, contain automatic notification of renewal facilities.

This facility is available across the majority of the DCMS. It allows for updates to be made to a complaint or an investigation, which are entered directly into the Evidence Log, and which can, at the same time be emailed internally, or externally to the complainant.

The unique reference number that is allocated to each complaint, allows for staff and correspondents to email directly into the DCMS, simply by emailing the given mail server address, with the appropriate complaint number in the Subject title.

Whilst the responsibility for compliance relies upon each individual organisation, the system has suggested guided pathways through the compliance process. For example, upon receipt of a SAR, the first process is to verify the identity of the complainant, as can be seen in the above image.

The system then guides a user through the completion of the process, suggesting appropriate options, at each stage. At any time, a user can step outside of the suggestions, using the ‘Update’ tool, which can be emailed both internally and externally.